Case Summary (G.R. No. 187801)
Procedural Background
The present case arises from a petition filed on June 15, 2009, challenging the orders dated July 7, 2008, and March 23, 2009, of the RTC of Tagum City. The July 7 order dismissed the petitioners’ complaint regarding the ownership of standing crops and improvements due to forum shopping, while the March 23 order denied reconsideration. The dismissal was based on the argument that the petitioners were concurrently pursuing the same matter before the Department of Agrarian Reform Adjudication Board (DARAB).
Antecedent Facts
The petitioners are heirs of several parcels of agricultural land in Davao Del Norte, which were leased to AMS Farming Corporation from 1970 to 1995. Upon the expiration of the lease, the lands were included in the Compulsory Acquisition Scheme of CARP, leading to a valuation by the Land Bank of the Philippines (LBP) for just compensation. Disputes arose over who was entitled to the compensation for standing crops and improvements on these lands, with AMS claiming ownership based on their involvement and the Memorandum of Agreement (MOA) with the petitioners.
Claim of AMS
During the administrative proceedings, AMS sought valuation for the standing crops and improvements based on their MOA with the petitioners. The LBP valued these crops and improvements at P32,326,218.82. However, when the petitioners attempted to intervene with their claim, their motion was denied on the ground that AMS's valuation had already been resolved. Eventually, a Consolidated Decision resulted in the awarding of just compensation to AMS for crops and improvements while awarding the petitioners for the raw lands.
Petitioners' Counterclaim
The petitioners asserted ownership over the crops and improvements, claiming that AMS's lease had expired and that they were entitled to the benefits thereafter. They contended that they never consented to the MOA and thus denied its validity. Despite further proceedings, their claims were dismissed, stating that AMS had established ownership through its investments in improvements and its registration of the crops for tax purposes.
RTC's Dismissal of the Petition
The RTC granted AMS's motion to dismiss the petitioners' complaint for failing to appeal the DARAB findings properly and for engaging in forum shopping. Essentially, it found that the same parties and subject matter were at issue in the previous DARAB proceedings. The petitioners' motions for reconsideration were denied, prompting them to seek recourse from the Supreme Court.
Arguments Presented by the Petitioners
The petitioners maintained that no valid prior judgment barred their complaint as the DARAB lacked jurisdiction over the ownership issue of the crops and improvements. They relied on the precedent established in a related case (Land Bank of the Philippines v. AMS Farming Corporation), which asserted that lessees could not claim compensation under CARP for crops and improvements made on property they did not own.
Legal Assessment and Court's Determination
The Supreme Court clarified that the procedural issues raised by the respondents, including claims of belated filing
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Overview of the Case
- The case involves a petition for the reversal of Orders dated July 7, 2008, and March 23, 2009, from the Regional Trial Court (RTC) of Tagum City, Davao Del Norte concerning Civil Case No. 3867.
- Petitioners include the heirs of Leonardo Banaag and spouses Pedro and Teresita Mendoza, claiming ownership of standing crops and improvements on agricultural land.
- The respondents are AMS Farming Corporation and the Land Bank of the Philippines (LBP).
Antecedent Facts
- Petitioners are the heirs of several parcels of land in Kapalong, Davao Del Norte, which were leased to AMS Farming Corporation from 1970 to 1995 for banana cultivation.
- A Memorandum of Agreement (MOA) extended the lease until September 30, 2002.
- The lands were subsequently covered by the Comprehensive Agrarian Reform Program (CARP), and LBP assessed the land values.
- Disputes arose over compensation for standing crops and improvements made by AMS on the land.
Claims and Counterclaims
- AMS claimed ownership of the crops and improvements based on the MOA, while the petitioners contended that ownership reverted to them after the lease expired in 1995.
- AMS filed for valuation of the crops, leading to an order by the Regional Agrarian Ref